The US continues to increase economic sanctions on Russia and Belarus. February 27 saw multiple actions expanding sanctions, including restrictions on exports of a large swath of equipment and consumer goods, Office of...more
With the ever-increasing use of sanctions as a foreign policy tool (or weapon), sanctions compliance has taken on greater importance than ever. Moreover, as countries increase extraterritorial applications of their sanctions,...more
In response to the Russian Federation’s recognition of certain regions of Ukraine as independent states which followed an expansion of nearly 200,000 troops on the Ukrainian border, US President Joseph Biden authorized the...more
The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) recently issued an “Updated Advisory on Potential Sanctions Risks for Facilitating Ransomware Payments.” This advisory continues prior advisory...more
10/4/2021
/ Cyber Attacks ,
Cybersecurity ,
FBI ,
Homeland Security Cybersecurity & Infrastructure Security Agency (CISA) ,
International Emergency Economic Powers Act (IEEPA) ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Ransomware ,
Regulatory Oversight ,
Sanctions ,
SDN List
The still evolving US sanctions (as well as the EU and now also separate UK sanctions) continue to challenge Russia-related business. The sanctions frameworks are complex, changing, and, at times, inconsistent as well as...more
3/23/2021
/ Bureau of Industry and Security (BIS) ,
CAATSA ,
Crimea ,
Economic Sanctions ,
EU ,
Foreign Policy ,
Infrastructure ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Russia ,
SDN List ,
UK ,
UK Brexit
The US Secretary of the Treasury announced sanctions this summer on 11 individuals who the Secretary views as being involved in implementing the recently enacted Law of the People’s Republic of China on Safeguarding National...more
President Donald Trump issued Executive Order 13936 on July 14 titled “The President’s Executive Order on Hong Kong Normalization” (the Executive Order or EO 13936). On the same day, the Hong Kong Autonomy Act (HR 7440) was...more
7/29/2020
/ China ,
Economic Sanctions ,
Executive Orders ,
Hong Kong ,
Hong Kong Autonomy Act (HKAA) ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Preferential Trade Status ,
Risk Management ,
SDN List ,
Trump Administration
Mexican President Andrés Manuel López Obrador recently announced that Mexico is willing to ship gasoline to Venezuela notwithstanding the threat of US sanctions against such activity. ...more
US persons who have engaged in wind-down or maintenance transactions with EN+ Group, UC Rusal, or JSC EuroSibEnergo (or entities they own or control) pursuant to General License 14E or 16E must report those transactions to...more
The Office of Foreign Assets Control recently designated 7 “oligarchs,” 17 government officials, 13 companies, and one bank, all Russian, as Specially Designated Nationals (SDNs), effectively prohibiting US persons...more
The new sanctions fall within the framework of existing US sanctions against Russia, but have expanded their application by classifying new, prominent individuals and companies as “Specially Designated Nationals.” Given the...more
Can the US government criminally prosecute non-US persons for activities that constitute secondary Iranian sanctions violations with no alleged nexus to the United States?...more